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IRS to Begin Enforcing 4980H Penalties on Large Employers Before End of 2017

On November 2, 2017, the IRS issued guidance regarding the enforcement of Employer Shared Responsibility payments, otherwise known as the Section 4980H penalty. Questions 55-58 of the IRS Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act indicate that the IRS is moving forward with assessing penalties on Applicable Large Employers […]

Former Associate

Agencies Come Down Hard on Various Employer Health Plans and Arrangements

As we move into 2015, employers continue to grapple with numerous Health Care Reform concepts.  Employers should be cautious regarding arrangements promoted to avoid health care penalties because the agencies are cracking down, as shown below. On November 4, 2014, the IRS and other agencies indicated that they have become aware that group health plans […]


Gear Up for Reporting of Health Coverage

Starting in 2016, Section 6055 of the Internal Revenue Code (the “Code”), which was added by the Health Care Reform Act, requires all entities providing “minimum essential coverage” (“MEC”) to submit information to the IRS concerning each covered individual for the 2015 calendar year.  Section 6055 also requires these entities to provide statements containing similar […]

Former Associate

Final Regs on Health Care Reform Large Employer Penalties May Help Employers Who Hire Employees From Staffing Firms

As explained in my Checklist for Employers, a large employer will have to pay a subsection (a) penalty for any month if it does not offer “minimum essential coverage” (“MEC”) to substantially all (i.e., 70% for 2015 and 95% for future years) of its full-time employees and their dependents if one or more full-time employees […]


What the heck is MEC?

Health care reform is confusing.  There are so many new terms and concepts.  One concept that has been getting a lot of attention lately is MEC.  MEC stands for “minimum essential coverage” and is a fancy name for basic health coverage. MEC is important for two main reasons — First, starting in 2014, individuals who don’t […]